Conditional Approval #220 December 1996
Comptroller of the Currency Administrator of National Banks Washington, DC 20219 Conditional Approval #220 December 2, 1996 December 1996 Mark J. Welshimer, Esquire Sullivan & Cromwell 125 Broad Street New York, N.Y. 10004-2498 Re: Notices of Wells Fargo Bank, N.A., Michigan National Bank, First National Bank of Chicago, and Texas Commerce Bank of Intent to Establish an Operating Subsidiary Pursuant to 12 C.F.R. § 5.34 to Become a Member of Limited Liability Companies Operating a Stored Value System - Application Control Nos. 96-WO-08-0012, -0013, -0025, and -0026 Dear Mr. Welshimer: This is in response to the operating subsidiary notices pursuant to 12 C.F.R. § 5.341, submitted on behalf of Wells Fargo Bank, N.A.(“Wells Fargo”), Michigan National Bank (“MNB”), First National Bank of Chicago, and Texas Commerce Bank, N.A. (collectively, the “Banks”), to establish operating subsidiaries to acquire membership interests in two Delaware limited liability companies (the “LLCs” or the “Companies”) that will operate a stored value card system known as “Mondex.” Each of the operating subsidiaries will be wholly owned by its parent Bank and will engage in no activities other than holding membership interests in the Companies. For the reasons discussed below, we approve, subject to certain conditions, the establishment of such operating subsidiaries by the Banks because we find that national banks may under 12 U.S.C. § 24(Seventh) engage in the business of developing and operating a stored value system. Please note that our response is solely directed to the question stated above. We do not address how other federal and state laws and regulations will or might apply to the Banks’ 1 The OCC recently amended its operating subsidiary rule , 12 C.F.R.
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